MINDMARKER PRIVACY POLICY

Introduction

Mindmarker, LLC. (“Mindmarker”, “us”, “our” or “we”) respects your privacy and is committed to protecting it through our compliance with this policy (“Privacy Policy”).
This Privacy Policy describes the personal information Mindmarker collects about you, and how we use and share that information. This policy applies to personal information we collect when you sign up for Mindmarker; access or use our website, products, or services (collectively, the “Services”); or when you otherwise interact with us, including through e-mail, text and other electronic messages. It does not apply to information collected by (i) us offline or through any other means, or (ii) any third party, including through any application or content (including advertising) that may link to or be accessible from our Services.
This Privacy Policy refers to personal information which is information that can be associated with a specific person and used to identify that person. Personal information does not include information that has been anonymized so that it does not identify a specific user, which may be used for any legal purpose.
This Privacy Policy covers the following topics:

Please read this policy carefully to understand our policies and practices regarding your personal information and how we will treat it. If you do not agree with our policies and practices, your choice is not to use our Services. By accessing or using our Services, you agree to this Privacy Policy.

Updates to the Privacy Policy

We may update, amend, revise or otherwise change this Privacy Policy from time to time. If we make changes, we will notify you by posting the updated policy and revising the “Effective Date” above. Your continued use of the Services constitutes your acceptance of the then-effective Privacy Policy.

Sources of Information About You

We obtain information about you from a variety of sources, including you, your interaction with Mindmarker, and third parties. Such information may include your name, postal address, e-mail address, and telephone number, among other personally identifiable information.

Information you provide to us: If you use certain Services, you may be required to provide us certain information.

Information that you provide by filling in forms on our website or app. This includes information provided at the time of registering to use our Services, subscribing to our Services, posting material or requesting further services.
We may also ask you for information when you report a problem with our Services.
Records and copies of your correspondence (including e-mail addresses), if you contact us.
Your responses to surveys that we might ask you to complete for research purposes.
Details of transactions you carry out through our Services and of the fulfillment of your orders.
Your search queries on our website or through our Services.

Information we collect from your use of the Services and other interactions you have with Mindmarker: We may collect your usage information about how you use the Services, including your access times, location, browser types and language, and Internet Protocol addresses. We may collect device-specific information when you access our Services, including your hardware model, operating system and version, unique device identifiers, mobile network information, and information about the device’s interaction with our Services.

The information we collect automatically is statistical data and may or may not include personal information, but we may maintain it or associate it with personal information we collect in other ways or receive from third parties. It helps us to improve and to deliver better and more personalized Services, including by enabling us to:

Estimate our audience size and usage patterns.
Store information about your preferences, allowing us to customize our Services according to your individual interests.
Speed up your searches.
Recognize you when you return to our Services.

The technologies we use for this automatic data collection may include:

Cookies (or browser cookies). A cookie is a small file placed on the hard drive of your computer. You may refuse to accept browser cookies by activating the appropriate setting on your browser. However, if you select this setting you may be unable to access certain parts of our Services. Unless you have adjusted your browser setting so that it will refuse cookies, our system will issue cookies when you direct your browser to our Services.

Information Provided by Other Sources. Other sources, for example your employer or training agency, can provide information to us about you. This is typically done when any organisation uses our service for their employees or clients.

Our Use of Information

We use information about you to provide, maintain, personalize and improve our Services, primarily our e-learning software service, and to deliver the information and support your requests, including receipts, technical notices, security alerts, and support and administrative messages.

We may use information we collect to send you news and information about our Services and to communicate with you about products, services, contests, promotions, incentives, and rewards offered by us and select partners. You may opt out of receiving promotional emails or any other messages from Mindmarker by following the instructions in those emails or messages. If you opt out, we may still send you non-promotional communications, such as messages about your account or our ongoing business relations.

We may also use information about you (i) to track and analyze trends and usage in connection with our Services; (ii) to process and deliver contest and promotion entries and rewards; (iii) to protect our rights or property; (iv) to compare information for accuracy; (v) to verify your identity; (vi) to investigate and prevent fraud or other illegal activities; and (vii) for any other purpose disclosed to you in connection with our Services.

Additionally, we use information that we collect about you or that you provide to us, including any personal information:

To provide you with information, products or services that you request from us.
To fulfill any other purpose for which you provide it.
To provide you with notices about your account/subscription, including expiration and renewal notices.
To carry out our obligations and enforce our rights arising from any contracts entered into between you and us, including for billing and collection.
To notify you about changes to our Services or any products or services we offer or provide though them.
In any other way we may describe when you provide the information.
For any other purpose with your consent.

We may use the information we have collected from you to enable us to display advertisements to our advertisers’ target audiences.

We may use third-party service providers to process and store personal information in the United States and other countries.

We may share personal information about you as follows:

To our subsidiaries and affiliates.
To contractors, service providers and other third parties we use to support our business and who are bound by contractual obligations to keep personal information confidential and use it only for the purposes for which we disclose it to them.
To comply with any court order, law or legal process, including to respond to any government or regulatory request.
To enforce or apply our terms of service, available at https://www.mindmarker.com/terms-of-service/, and other agreements, including for billing and collection purposes.
If we believe disclosure is necessary or appropriate to protect the rights, property, or safety of Mindmarker, our customers or others. This includes exchanging information with other companies and organizations for the purposes of fraud protection and credit risk reduction.
To a buyer or other successor in the event of a merger, divestiture, restructuring, reorganization, dissolution or other sale or transfer of some or all of Mindmarker’ assets, whether as a going concern or as part of bankruptcy, liquidation or similar proceeding, in which personal information held by Mindmarker about our users is among the assets transferred.
To fulfill the purpose for which you provide it.
With third parties that run advertising campaigns, contests, special offers, or other events or activities in connection with our Services.
For any lawful purpose.
With your consent or direction.

We may also share non-personally identifiable information (aggregated or otherwise) with third parties for any reason.
We are committed to providing you with clear, conspicuous, and readily available mechanisms to exercise choice. Therefore, in addition to any other mechanisms that may be already provided in particular cases, individuals may opt-out from any personal data being disclosed to a third party or to be used for a purpose that is materially different from the purpose(s) for which it was originally collected or subsequently authorized by the individual. To do so please contact us at: dataprivacy@mindmarker.com.

Legal Basis for Processing Personal Data Under General Data Protection Regulation (GDPR)

If you are from the European Economic Area (EEA), our legal basis for collecting and using the personal information described in this Privacy Policy depends on the Personal Data we collect and the specific context in which we collect it.

We may process your Personal Data because:

We need to perform a contract with you
You have given us permission to do so
The processing is in our legitimate interests and it’s not overridden by your rights
To comply with the law

Retention of Data

We will retain your Personal Data only for as long as is necessary for the purposes set out in this Privacy Policy. We will retain and use your Personal Data to the extent necessary to comply with our legal obligations (for example, if we are required to retain your data to comply with applicable laws), resolve disputes, and enforce our legal agreements and policies.

We will also retain Usage Data for internal analysis purposes. Usage Data is generally retained for a shorter period of time, except when this data is used to strengthen the security or to improve the functionality of our Service, or we are legally obligated to retain this data for longer time periods.

International Transfer Of Data

Your information, including Personal Data, may be transferred to — and maintained on — computers located outside of your state, province, country or other governmental jurisdiction where the data protection laws may differ than those from your jurisdiction.

If you are located outside United States and the EU choose to provide information to us, please note that we transfer the data, including Personal Data, to United States and the EU and process it there.

Your consent to this Privacy Policy followed by your submission of such information represents your agreement to that transfer.

We will take all steps reasonably necessary to ensure that your data is treated securely and in accordance with this Privacy Policy and no transfer of your Personal Data will take place to an organization or a country unless there are adequate controls in place including the security of your data and other personal information.

EU-U.S. And Swiss-U.S. Privacy Shield

Mindmarker, LLC complies with the EU-U.S. Privacy Shield and the Swiss-U.S. Privacy Shield Framework(s), as applicable) as set forth by the U.S. Department of Commerce regarding the collection, use, and retention of personal information transferred from the European Union and/or Switzerland, as applicable) to the United States. Mindmarker, LLC is certified by the Department of Commerce that it adheres to the Privacy Shield Principles. If there is any conflict between the terms in this privacy policy and the Privacy Shield Principles, the Privacy Shield Principles shall govern. To learn more about the Privacy Shield program, and to view our certification, please visit https://www.privacyshield.gov/

With respect to personal data received or transferred pursuant to the Privacy Shield Framework, Mindmarker is subject to the regulatory enforcement powers of the U.S. Federal Trade Commission. In certain situations, Mindmarker may be required to disclose personal data in response to lawful requests by public authorities, including to meet national security or law enforcement requirements.
In compliance with the Privacy Shield Principles, Mindmarker commits to resolve complaints about our collection or use of your personal information. EU and Swiss individuals with inquiries or complaints regarding our Privacy Shield policy should first contact Mindmarker at: dataprivacy@mindmarker.com.

Mindmarker is responsible for the processing of personal data it receives under the Privacy Shield Framework and subsequently transfers to a third party acting as an agent on its behalf. Mindmarker complies with the Privacy Shield Principles for all onward transfers of personal data from the EU and Switzerland, including the onward transfer liability provisions.

Mindmarker has further committed and you agree to refer unresolved Privacy Shield complaints to the International Centre for Dispute Resolution, the international division of the American Arbitration Association (ICDR/AAA), an alternative dispute resolution provider located in the United States. If you do not receive timely acknowledgment of your complaint from us, or if we have not addressed your complaint to your satisfaction, please visit http://go.adr.org/privacyshield.html for more information or to file a complaint. The services of ICDR/AAA are provided at no cost to you.

If you are a resident of the European Economic Area (EEA), you have certain data protection rights. Our organisation aims to take reasonable steps to allow you to correct, amend, delete, or limit the use of your Personal Data.

If you wish to be informed what Personal Data we hold about you and if you want it to be removed from our systems, please contact us.

In certain circumstances, you have the following data protection rights:

The right to access, update or to delete the information we have on you. Whenever made possible, you can access, update or request deletion of your Personal Data directly within your account settings section. If you are unable to perform these actions yourself, please contact us to assist you.
The right of rectification. You have the right to have your information rectified if that information is inaccurate or incomplete.
The right to object. You have the right to object to our processing of your Personal Data.
The right of restriction. You have the right to request that we restrict the processing of your personal information.
The right to data portability. You have the right to be provided with a copy of the information we have on you in a structured, machine-readable and commonly used format.
The right to withdraw consent. You also have the right to withdraw your consent at any time where Mindmarker LLC relied on your consent to process your personal information.

Please note that we may ask you to verify your identity before responding to such requests.

You have the right to complain to a Data Protection Authority about our collection and use of your Personal Data. For more information, please contact your local data protection authority in the European Economic Area (EEA).

Links to Other Web Sites; Third Party Applications

Mindmarker is not responsible for any practices employed by websites linked to or from our website, nor their information or content. Please remember that when you use a link to go from our website to another website, this Privacy Policy is no longer in effect. Your browsing and interaction on any other website is subject to that website’s own rules and policies. Please read over those rules and policies before proceeding. Additionally, some content or applications, including advertisements, on or through the Services are served by third-parties, including advertisers, ad networks and servers, content providers and application providers. These third parties may use cookies, alone or in conjunction with web beacons or other tracking technologies, to collect information about you when you use our Services. The information they collect may be associated with your personal information or they may collect information, including personal information, about your online activities over time and across different websites and other online services. They may use this information to provide you with interest-based (behavioral) advertising or other targeted content. We do not control these third parties’ tracking technologies or how they may be used. If you have any questions about an advertisement or other targeted content, you should contact the responsible provider directly.

Service Providers

We may employ third party companies and individuals to facilitate our Service (“Service Providers”), to provide the Service on our behalf, to perform Service-related services or to assist us in analyzing how our Service is used.

These third parties have access to your Personal Data only to perform these tasks on our behalf and are obligated not to disclose or use it for any other purpose.

Analytics

We may use third-party Service Providers to monitor and analyze the use of our Service.

Google Analytics – Google Analytics is a web analytics service offered by Google that tracks and reports website traffic. Google uses the data collected to track and monitor the use of our Service. This data is shared with other Google services. Google may use the collected data to contextualize and personalize the ads of its own advertising network.For more information on the privacy practices of Google, please visit the Google Privacy Terms web page: http://www.google.com/intl/en/policies/privacy/
Firebase – Firebase is analytics service provided by Google Inc. You may opt-out of certain Firebase features through your mobile device settings, such as your device advertising settings or by following the instructions provided by Google in their Privacy Policy: http://www.google.com/intl/en/policies/privacy/ We also encourage you to review the Google’s policy for safeguarding your data: https://support.google.com/analytics/answer/6004245. For more information on what type of information Firebase collects, please visit please visit the Google Privacy Terms web page: http://www.google.com/intl/en/policies/privacy/

Children’s Privacy

Our Service does not address anyone under the age of 16 (“Children”).

We do not knowingly collect personally identifiable information from anyone under the age of 16. If you are a parent or guardian and you are aware that your Children has provided us with Personal Data, please contact us. If we become aware that we have collected Personal Data from children without verification of parental consent, we take steps to remove that information from our servers.

Security

We safeguard the security of your personal information with industry-standard physical, electronic, and managerial procedures. The safety and security of your personal information also depends on you. Where we have given you (or where you have chosen) a password for access to certain parts of our Services, you are responsible for keeping this password confidential. We ask you not to share your password with anyone. Unfortunately, the transmission of information via the internet is not completely secure. Although we do our best to protect your personal information, we cannot guarantee the security of your personal information transmitted to or through our Services. Any transmission of personal information is at your own risk. We are not responsible for circumvention of any privacy settings or security measures contained on or within the Services.

Contact Us

If you have any questions about this Privacy Policy, please contact us:

By email: support@mindmarker.com

Privacy Policy